Part of the CustodyStress archive of observed Bitcoin custody incidents
CS-01357
Sanctions lockout — exchange custody (2025)
BlockedCase description
Garantex, a Russia-based cryptocurrency exchange that had been sanctioned by OFAC in April 2022 for facilitating transactions for sanctioned entities, was targeted by a second coordinated enforcement action in March 2025. US, European, and German authorities seized Garantex's web domains and arrested the platform's operator. The seizure effectively cut off all access for Garantex users—primarily Russian nationals—who had cryptocurrency balances on the exchange. Because the platform had been operating under sanctions since 2022, any users who had left funds on it were already in a legally ambiguous situation; the seizure resolved that ambiguity definitively by eliminating access.
Custody context
| Stress condition | Vendor lockout |
| Custody system | Exchange custody |
| Outcome | Blocked |
| Documentation | Unknown |
| Year observed | 2025 |
| Country | International |
Structural dependencies observed
What this illustrates
Before anyone could access the funds, a legal process had to be completed first. Access was not recoverable.
Outcome interpretation
Access was not possible under the reported conditions.
Source
Publicly Reported
Evidence type
News article
Related cases involving vendor lockout
This archive documents observed custody survivability failures. It does not attempt to document all Bitcoin losses or security incidents.
Submit a case
← All cases
Framework references
Where Bitcoin Custody Intersects Legal and Fiduciary Authority
Where custody creates gaps in estate planning, fiduciary duty, and professional responsibility.
Professional Scope Boundary Matrix
What each professional or product covers, what they do not, and where gaps form between them.
The Independent Assessment Layer in Bitcoin Custody
How independent diagnostic layers emerge when multiple parties depend on shared infrastructure.
Translate